§66611

for 1988, 1989, 1990, and 1991, as determined by respondent; (2) whether petitioner is liable for the additions to tax for failure to file timely returns for 1988, 1989, and 1990; (3) whether petitioner is liable for the addition to tax pursuant to section 66611 for an understatement of income tax on his 1988 Federal income tax return; and (4) whether petitioner is liable for the accuracy-related penalties pursuant to section 6662(c) for 1989, 1990, and 1991.

Respondent further determined that petitioner is liable for an addition to tax in the amount of $12,386 pursuant to section 66611 for a substantial understatement of income tax.

Respondent also determined an addition to tax of $40,349 under section 66611 for taxable year ended July 31, 1989, 1 All section references are to the Internal Revenue Code in (continued...) - 2 - and an accuracy-related penalty of $28,170 under section 6662(a) for taxable year ended July 31, 1990.

Respondent determined a deficiency in petitioners’ 1982 Federal income tax in the amount of $391,113, and an addition to tax under section 66611 in the amount of $97,778.50.

GERBER, Judge: Respondent alternatively determined a $540,716 income tax deficiency and a $135,179 addition to tax under section 66611 for the 1985 tax year, or a $537,808 income tax deficiency and a $107,562 addition to tax under section 6661 for the 1986 tax year.

MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined a deficiency in petitioner's Federal income tax for 1986 of $8,414 and an addition to tax for substantial understatement of tax under section 66611 of $2,104.